EVOLLU PRIVACY POLICY
SENSING EVOLUTION, LDA (ahead, EVOLLU), headquartered in Rua Comissão Iniciativa, 2ª, piso 7, Edifício Torre Brasil, 2410-098 Leiria and VAT 513 758 747 is a company that owns the EVOLLU’s APPLICATION (ahead, APP).
EVOLLU IS FOCUSED ON PROTECTING THE PRIVACY AND PERSONAL DATA OF ITS CUSTOMERS AND USERS OF THE APP, WHEREFORE, IT HAS PREPARED AND ADOPTED THE PRESENT POLICY AND THE PRACTICES DESCRIBED HEREIN. THIS PRIVACY POLICY EXPLAINS HOW WE USE YOUR PERSONAL DATA, AND, THEREFORE, WE ADVISE READING IT SO AS TO KNOW THE CONDITIONS UNDER WHICH YOUR PERSONAL DATA IS COLLECTED AND PROCESSED.
1.1. This Privacy Policy explains how we collect and process the personal data that are necessary for the provision of services that are available trough the APP.
1.2. The objective is that these services are provided in an expeditious and undisturbed way, describing the practices adopted for this purpose.
2.1. Personal data is any information relating to a person and that identifies that person or makes it identifiable, regardless of the nature or support of that information, and including the sound and image of that person.
2.2. Examples of personal data we are collecting are the hearing test results.
2.3. The term ”identifiable“ refers to a person who can be identified, directly or indirectly, in particular by reference to an identification number or other specific elements of his or hers physical, physiological, psychic, economic, cultural or social identity.
3.1. EVOLLU will use the personal data you provide us for the following purposes:
(a) To analyse your hearing test results;
(b) To analyse and to respond to your messages, customer support and inquiries;
(c) To create an account in the APP;
(d) For operations and management of the APP;
(e) To keep track of your contact details;
(f) For commercial purposes, such as data analysis, audits;
(g) For fraud prevention and information system safetiness;
(h) For adaptation, improvement and modification of services, in particular by identifying trends in use, or to determine the effectiveness of promotional campaigns;
(i) For the expansion of EVOLLU´s commercial activities.
3.2. These operations of personal data processing are an essential tool for your satisfaction and for the activity of EVOLLU and are carried out according to the applicable legislation and following the best practices.
3.3. Your personal data will not be reused for any other purposes not previously identified or that have nothing to do with those purposes for which they were initially collected for.
4.1. The personal data that EVOLLU processes has specific grounds according to the purposes for which they are intended to.
4.2. In the following table you can see the legal basis grounds for processing regarding the above mentioned purposes:
|
PURPOSES |
LEGAL BASIS |
|
To analyze your hearing test results from; |
Consent for this specific purpose; |
|
To analyze and respond to your messages, customer support and inquiries; |
Consent for this specific purpose; |
|
To create an account in the APP. |
Consent for this specific purpose; |
|
For operations and management of the APP; |
Consent for this specific purpose; Legitimate interests pursued by EVOLLU; |
|
To keep track of your contact details; |
Consent for this specific purpose; |
|
For commercial purposes, such as data analysis, audits; |
Consent for this specific purpose; Legitimate interests pursued by EVOLLU; |
|
For fraud prevention and information system safetines; |
Legitimate interests pursued by EVOLLU; |
|
For the adaptation, improvement and modification of services, in particular by identifying trends in use, or to determine the effectiveness of promotional campaigns; |
Consent for this specific purpose; Legitimate interests pursued by EVOLLU; |
|
For the expansion of EVOLLU´s commercial activities. |
Legitimate interests pursued by EVOLLU; |
5.1. The personal data that EVOLLU collects and processes are only those which are necessary and suitable for the above mentioned purposes.
5.2. EVOLLU will collect and process the following personal data:
|
PURPOSE |
DATA |
|
To analyze your hearing test results from; |
Questions of the hearing test results. |
|
To analyze and respond to your messages, customer support and inquiries; |
Name and Email. |
|
To create an account in the APP. |
Name, last name, email, password, phone number, gender, date of birth, |
|
For operations and management of the APP; |
Geolocation data. |
|
To keep track of your contact details; |
Name and Email. |
|
For commercial purposes, such as data analysis, audits; |
Geolocation data. |
|
For fraud prevention and information system safetines; |
Name, e-mail and Geolocation data. |
|
For the adaptation, improvement and modification of services, in particular by identifying trends in use, or to determine the effectiveness of promotional campaigns; |
Name, email and Geolocation data. |
|
For the expansion of EVOLLU´s commercial activities. |
Name and Email. |
6.1. We will collect your personal data through the forms on the APP, but also through the APP and the communication that it makes with your device and e-mail messages that you send us.
6.2. Your personal data is collected through your equipment as follows:
(a) Through your user’s data account.
6.3. EVOLLU is committed to process your data lawfully and legally.
6.4. EVOLLU will not sell, rent or share your personal data with third parties, with the exception of the clearly identified cases in this Privacy Policy (see Point 10 to understand how).
6.5. EVOLLU’s services are not intended for minors and no personal details of minors are or will being processed intentionally.
7.1. Your personal data are kept safe through the adoption of various security measures, of technical and organisational nature that assure that only the employees have access to the data, and to the processes to access them, according to the rules created for that particular purpose.
7.2. In order to protect your personal data, we only use data center providers who provide us with adequate and documented security measures, namely guarantee that your personal data is stored in servers that are kept in controlled environments with limited access.
7.3. Your data are kept in secure servers next to Google Data Centers (ahead, “Google Data Center”) located in Eemshaven, Netherlands which offers us all necessary security safeguards that allow for data protection against its diffusion, loss, misuse, alteration, processing or unauthorised access as well as against any other form of illicit processing.
7.4. Similarly, when browsing through the APP, we protect your data through the use of encryption, such as Transport Layer Security (TLS) and your password is stored using an unidirectional hash, in other words, it cannot be retrieved (or disclosed) by anyone, including EVOLLU, and can only be redefined.
7.5. Although we take all the necessary precautions that we deem to be appropriate to protect the personal data you provide and that we collect, one must be aware that no security system is impenetrable.
7.6. Therefore, you should take certain precautions, such as keeping your password secret and not disclosing it to anyone; If you think your password has been misused, you should let us know right away; You should also be careful when starting and ending your session every time the browser closes.
8.1. Your personal data will be kept for the time required for the purposes for which they are intended, as set forth in this Privacy Policy, as follows:
|
PURPOSE |
PERIOD |
|
To analyze your hearing test results from; |
2 years |
|
To analyze and respond to your messages, customer support and inquiries; |
1 year |
|
To create an account in the APP. |
During the period of use of the application, and 24 months after the last access to it. |
|
For operations and management of the APP; |
2 years |
|
To keep track of your contact details; |
2 years |
|
For commercial purposes, such as data analysis, audits; |
2 years |
|
For fraud prevention and information system safetines; |
2 years |
|
For the adaptation, improvement and modification of services, in particular by identifying trends in use, or to determine the effectiveness of promotional campaigns; |
2 years |
|
For the expansion of EVOLLU´s commercial activities. |
2 years |
8.2. If any specific or mandatory period of time is required by law, the data’s retention period will be such mandatory period. In all other cases, the personal data will be kept, at most, during the above mentioned time periods, which EVOLLU deems as sufficient to fulfil its purposes.
8.3. At the end of the storage period, all collected personal data will be deleted.
9.1. Before we explain how you can exercise your rights, you should know what are your rights. Thus, the law grants you the right to request us the exercise of the following rights:
(a) Access: the right to confirm whether your personal data is being processed or not, and, if so, the right to access your personal data;
(b) Rectification: the right to rectify any inaccuracy regarding your personal data and to complete personal data that might be incomplete;
(c) Erasure: the right to erase your personal data when one of the listed grounds in the legislation is applicable;
(d) Restriction of processing: the right to limit data processing, if one of grounds listed in the legislation is applicable;
(e) Objection: the right to object, at any time, to the processing of your personal data;
(f) Data portability: the right to receive your personal data, which you provided, in a structured, commonly used and machine-readable format.
9.2. You have also the right to lodge a complaint with a supervisory authority (National Data Protection Commission at www.cnpd.pt)
9.3. For the purpose of exercising the rights above mentioned, you should contact EVOLLU via this email info@evollu.com.
9.4. If you ask us to delete some, or all, of your personal data, some of the requested services may not be provided to you and EVOLLU will keep the necessary personal data to fulfil its legal obligations.
10.1. EVOLLU may use third parties to provide certain services, such as maintenance, technical support, marketing, billing or payment management, which may have access to some personal data, in particular, data required for contractual purposes.
10.2. EVOLLU ensures that the entities that have access to the data are credible and offer high guarantees of protection, and that that data will never be transmitted beyond what is necessary to provide for the contracted service, nevertheless EVOLLU remains responsible for the personal data made available.
10.3. For example, for the purposes of data center management, EVOLLU uses the services provided by Google Data Center.
10.4. EVOLLU may also transmit its data to (a) companies in its business group with whom EVOLLU has commercial partnerships to create and offer benefits or (b) to other partners outside its business group (in this case, it will be done with your prior authorisation).
10.5. EVOLLU may also transmit data to third parties in the context of research, inquiries and judicial and / or administrative processes or of similar nature, provided that it is duly ordered by a court or law.
12.1. If data transfers to non-EU countries occur, EVOLLU will comply with the law, in particular regarding to the data protection adequacy of the country to where the personal data will be transferred to, and the requirements applicable to such transfers. Therefore, personal data will not be transferred to jurisdictions that do not offer security and protection assurances.
13.1. The APP is not intended for minors under the age of 18, thus, we request that minors do not provide us with personal information through the APP, social media and/or emails.
14.1. EVOLLU will collect and process user’s health data, within the scope of the analysis hearing test results as they are necessary to perform this purposes, and will comply with all technical and organisational safety measures.
15.1. EVOLLU reserves the right to readjust or change this Privacy Policy at any time, as these changes are advertised.
16.1. If you have any questions or concerns regarding this Privacy Policy, please contact us by writing to us via email info@evollu.com.
17.1. 01 10, 2020. Leiria (Portugal)